Case Digest (G.R. No. 179714)
Facts:
The case involves Rodolfo Lopez as the appellant and the People of the Philippines as the appellee. The events leading to the case began on June 11, 1998, when AAA, the mother of the victim BBB, left her home in Barangay XXX, Camarines Norte, to collect credit, leaving her four-year-old daughter BBB in the care of Rodolfo Lopez, an employee of her husband. The following day, AAA took BBB to a manghihilot due to a fever and stomachache. During this visit, BBB requested her mother to wash her vagina, which led AAA to notice that BBB's private organ was swollen and had a small amount of blood. On June 13, 1998, despite still being ill, BBB insisted on taking a bath, during which AAA observed that her vagina remained swollen. When questioned, BBB pointed to Rodolfo Lopez and stated, "It was Kuya Aswang," indicating that he had assaulted her.
AAA confronted BBB about whether Lopez had inserted his penis into her vagina, to which BBB affirmed. BBB recounted that Lo...
Case Digest (G.R. No. 179714)
Facts:
Incident Details:
- On June 11, 1998, around 5:00 PM, AAA left her house to collect credit, leaving her 4-year-old daughter, BBB, and appellant Rodolfo Lopez, an employee of her husband, at home.
- The next day, June 12, 1998, BBB complained of a fever and stomachache. AAA brought her to a manghihilot (traditional healer). While washing BBB’s vagina, AAA noticed swelling and a small amount of blood, initially assuming it was due to an accidental bump.
- On June 13, 1998, BBB revealed that appellant Lopez had sexually assaulted her, stating, "It was Kuya Aswang," and described how he removed her underwear, placed himself on top of her, and inserted his penis into her vagina.
Medical Examination:
- On June 15, 1998, BBB was examined by Dr. Marcelito B. Abas, who found a superficial hymenal laceration at the 9 o’clock position, consistent with penetration by an erect penis.
Legal Proceedings:
- An Information was filed on July 17, 1998, charging appellant Lopez with Statutory Rape under Article 335 of the Revised Penal Code, as amended by RA 8353.
- During the trial, the prosecution presented testimonies from AAA, BBB, and Dr. Abas, along with other witnesses. The defense relied solely on appellant Lopez’s testimony, where he denied the allegations and instead accused BBB’s 6-year-old brother of inserting his finger into her vagina.
Trial Court Decision:
- The Regional Trial Court (RTC) found appellant Lopez guilty beyond reasonable doubt and sentenced him to death. The case was appealed to the Court of Appeals (CA) due to the imposition of the death penalty.
Court of Appeals Decision:
- The CA affirmed the RTC’s decision but modified the penalty to reclusion perpetua, in accordance with RA 9346, which prohibits the death penalty.
Issue:
- Whether the trial court erred in convicting appellant Lopez based on the weakness of the defense’s evidence rather than the strength of the prosecution’s evidence.
- Whether the prosecution proved beyond reasonable doubt that appellant Lopez committed statutory rape.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)